Tag Archives: Green Belt

A Tactical Withdrawal, temporary Reprieve? What is going on at Castle Point Council and its Local Plan?

In a letter from Castle Point Council, dated 31st May 2017, we learn of the latest developments in the Persimmons proposal to develop the Dutch Village Green Belt;

Dear Sir/Madam

 

Proposal: Erect up to 275 new homes and retail/community facilities (use classes A1, A2, A3, A4, A5, C2 and/or D1) with new roundabout junction onto A130 Canvey Road, associated parking, open space, ecological enhancements, landscaping, drainage and flood mitigation measures (outline)
Location: Land To The East Of Canvey Road Canvey Island Essex

 

I refer to my consultation letter in respect of the above application and write to advise you that the application has been withdrawn and the Council will not therefore take any further action in the matter.

 

I thank you for your interest in the proposal and I will ensure that you are consulted again if a further application is submitted in the future.

 

Yours faithfully,

S Rogers

Head of Regeneration & Neighbourhoods

Fair Play for Canvey Island in the light of the Jotmans Decision or are we still a “Special Case”?

And the Necessity for Castle Point Borough Council to produce a Local Plan is?

“National planning policy places Local Plans at the heart of the planning system,”

Even so, the National Planning Policy Framework states as early as Paragraph 14;

“Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless:

– any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole;

or– specific policies in this Framework indicate development should be restricted. 9

Paragraph 14, Footnote 9 Reads; “For example, those policies relating to sites protected under the Birds and Habitats Directives (see paragraph 119) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, Heritage Coast or within a National Park (or the Broads Authority); designated heritage assets; and locations at risk of flooding or coastal erosion.”

“so it is essential that they are in place and kept up to date. Local Plans set out a vision and a framework for the future development of the area, addressing needs and opportunities in relation to housing, the economy, community facilities and infrastructure – as well as a basis for safeguarding the environment, adapting to climate change and securing good design.”

The Secretary of State’s decision to dismiss the Jotmans Farm Appeal in the light of the Inspector’s recommendation, raises some questions.

Is the Planning Inspectorate’s reading of the NPPF and Guidance similar to that of the Government’s?

There was agreement between the SoS and the Inspector that, Castle Point Council are only able to identify 0.4 years worth of the required 5 Year deliverable Housing Supply, this is an even worse supply than in 2013 when the SoS considered cpbc had a realistic housing supply of just 0.7 years!

In the case of the Glebelands 2013 Inquiry the SoS used a “totting-up” method of measuring harm to the Green Belt;

“the Secretary of State has identified moderate harm in respect of urban sprawl, moderate harm in respect of the merging of neighbouring settlements, and moderate harm to the visual appearance of this part of the GB.  The Secretary of State considers that together this represents a considerable level of harm. ”

” He also wishes to emphasise that national policy is very clear that GB reviews should be undertaken as part of the Local Plan process.”

So we appear to be in a situation where, as long as Castle Point council are in an apparent perpetual process of Local Plan making, the whole of the local Green Belt can be considered safe from development!

Residents should now be looking for a new, up to date cpbc Green Belt Review, based on the SoS’ guidance and embracing the protection afforded by Footnote 9 of the NPPF.

As was pointed out earlier in this post;

“Local Plans should meet objectively assessed needs, … unless: – ….  specific policies in this Framework indicate development should be restricted – For example, those policies relating to …. land designated as Green Belt, Local Green Space, … and locations at risk of flooding.”

This appears to be the clear desire of the Secretary of State’s interpretation of planning direction. The archived cpbc Green Belt Review was dated 2013 and produced in-house in support of the rejected daft New Local Plan, and clearly out of line with the Secretary of State’s consideration of  levels of “harm.” A new GB Review should be commissioned urgently, indicating the protection available through NPPF Policies and Guidance!

It would appear that the Castle Point council’s Local Plan2016, despite their failure to comply with the Duty to Cooperate with neighbouring local authorities, may have been more in tune with the Secretary of State’s interpretation of what is possible with Local Plan-making and stood a chance of being considered adoptable. Whilst an Inspector may feel the Local Plan2016 was worthy of withdrawal, seeking intervention via the Secretary of State, may supply a different decision, once the Duty to Cooperate has been complied.

More importantly, with Canvey Island in mind, is that NPPF Footnote 9 offers no  difference in the weight and importance that should be applied when considering whether a site is appropriate for development between that of Green Belt or Flood Risk!

Only in the minds of those in Control of Decision-making within Castle Point council, is Canvey Island deemed a “special case”!

If not now, then I do not know when, given the position of the cpbc Local Plan, and the direction given by the SoS, it would be more Timely and more Appropriate for Canvey Island Town Council to undertake a Neighbourhood Plan!

The Secretary of State is clear Footnote 9 should be applied to protect Green Belt from Harm.

It is obvious that an area within a Flood Risk Zone and with unresolved Surface Water Flooding issues, can expect that same level of protection using Neighbourhood Plan Policies under-pinned by that same Footnote 9!

Quite simply Canvey Island is thought to be unlikely to Flood. This is supported by no factual Evidence, simply that it is “unlikely”. The continual loss of Green Space to development on Canvey that serves as potential displacement for flood water, fails to register any concern to the planning decision makers!

The FloodRe insurance scheme is limited, limited so that it specifically discourages development in Flood Risk areas.

The list of properties excluded from the remit of Flood Re has been subject to significant debate however it has been agreed that the following properties will not be covered:

  • All commercial property
  • All residential property constructed since 1 January 2009
  • All purpose-built apartment blocks

Who will weigh this against Financial Sustainability? It appears nobody at Castle Point council!

It is time for the reservations contained within the NPPF Footnote 9 to be considered appropriately and evenly across the whole of Castle Point!

” ” All quotations lifted from the NPPF, Planning Guidance, Glebelands Inquiry and the Jotmans Farm Inquiry.

“Smoke Filled Rooms, Dodgy Housing Site Selection Processes and Failed Local Plans,” sound Familiar?

Yet another Local Plan is halted in its Tracks. In an Inspector’s Note, reminiscent of that sent to Castle Point Council during 2011 when Mr P.Crysell stated, amongst other concerns; 

“I consider there remain serious shortcomings in the (CPBC) Council’s Plan.” “These are firstly, the approach in relation to the Green Belt; secondly, the consequences of this on the distribution of growth across the Borough”

“I have reservations about the methodology employed and the way in which it appears to have been used, leading to inconsistent and inappropriate site selection.  For example, the Council’s own Sustainability Appraisal is unclear as to why the most sustainable Green Belt site was discounted.”

“I consider it would be difficult to endorse a strategy which commits to Green Belt release in an area of potential high flood risk at Canvey Island yet fails to identify more than a token amount of land on the mainland where flooding is not a significant issue.”

The Shropshire Star commented of the Telford and Wrekin Local Plan;

“It is pretty clear that a ‘smoke filled’ room process occurred behind closed doors with Cllrs where political rather than policy issues dominated – something the post 2004 Act changes was designed to eliminate.”  Shropshire Star

Evidence had emerged of a similar smoke filled room meeting in the CPBC Lead Group rooms, during which Canvey Island Green Belt was sacrificed so as to progress a Core Strategy document bent on protecting mainland Green Belt at all costs!

Of the Telford and Wrekin Local Plan the Inspector commented;

Housing Site Selection Methodology

 7. You will recall the concerns that I raised at the Matter 8 hearing session in respect of this matter.  While I accept the need for a Plan’s evidence base to be proportionate, it is also the case that all parties need to understand why certain sites were allocated and why other sites were not allocated.

 8. In that context, I sought to examine the methodology that the Council has employed in selecting the 17 housing sites proposed for allocation in the Plan.  Unfortunately, the commentary set out in the Council’s (pre-hearing) written answer to my question in respect of this matter2 and in section 5 of the Housing Delivery Technical Paper3 contain only a brief summary of that process.  Indeed, the latter document states (para 5.6) that ‘the site selection or rejection reasons for each individual site can be found in the Integrated (Sustainability) Appraisal Report (2015)’ (the IA).

 9. However, Appendix X of the Integrated (Sustainability) Appraisal Report4 comments that ‘the IA findings are not the sole basis for a decision; other factors including planning and deliverability, play a key role in the decision-making process’.  Bearing in mind the position set out in Housing Technical Paper as described above, this suggests to me an element of circular reasoning.  

 10. Clearly, the detailed selection of sites for allocation involves an element of planning judgement.  However, that judgment needs to be both explicit and transparent.  In short, there needs to be a clear ‘audit trail’ that shows how the final decisions were arrived at, and what factors were taken into account in making such decisions.

 11. In response to my questions along those lines at the Matter 8 Hearing session, your officers offered to table working spreadsheets that would give more information about how the Council reached its decisions in this regard.  I accepted that suggestion and allowed other parties the opportunity to make representations accordingly.  However, the document that was subsequently produced5 was not the working spreadsheet that had originally been offered.  Instead it represents a commentary, apparently prepared after the event, that seeks to apply planning considerations to some (but not all) of the sites that were considered at the ‘strategic fit’ stage of the site assessment process.  I have now been advised that the Council is unable to find the spreadsheets that were apparently referred to at the hearing session.

12. The evidence that has been submitted since the hearing session is inadequate for several reasons.  First, it does not represent the actual selection exercise, as it was prepared after the event.  Second, comments are only given on a number of some 315 sites considered at the ‘strategic fit’ stage of the assessment.  Over 200 sites are missing.  This represents a substantial gap in the evidence base.  While the Council comments that the sites listed are only those that scored 5 or above in that exercise, it is clear that some sites with a lower score were also assessed – and indeed subsequently allocated in the Local Plan.  Clearly, an additional sieving exercise had taken place prior to the one that is presented in the new evidence.  Third, it is clear from the comments made in this document that a number of sites that scored highly against the ‘strategic fit’ criteria were then discounted on the basis of their existing use.  It is unclear why these were not screened out at the earlier site assessment stage, at which the site’s development potential was considered in terms of various factors – including use.

 13. I note the Council’s responses to the specific comments made by representors in respect of this additional evidence7.  For the avoidance of doubt, the present note does not seek to comment on the detailed scores that have been assigned to specific sites in the IA.  However, I share a general concern raised by some parties in respect of strategic fit criterion 2 (promoting sustainable urban extensions) that it is not immediately clear why some large sites (notably those that have been allocated) were given a positive score in respect of that criterion while other large sites – also adjoining the urban area – were deemed to not comprise a sustainable urban extension.

16. Drawing these matters together, and noting that some further comments are yet to be submitted by the Council, it appears likely that I will reach a finding that the housing site selection exercise underpinning the Local Plan is flawed.  Such a finding would call into question my ability to reach a finding of soundness on a Local Plan containing these site allocations.

13 years on from the 2004 Act, that the Shropshire Star referred to, appears to have resulted in very little impact!

£?,000,000 Block Buster – a Decade in the making Castle Point Local Plan IV – the Sequel! “Missing the Point”

download

“Fear not, for I have a plan!”

Castle Point Residents should be concerned as to why Local Plan Version III has ended in withdrawal with the vast waste of time and tax payers monies.

The Examining Inspector pinpointed the failure of the Castle Point council’s legal duty to have engaged constructively with neighbouring local authorities, actively and on an ongoing basis so as to prepare an effective Local Plan, in the context of strategic cross boundary matters.

The Duty to Cooperate work requirement, supports the evidence base that in turn supports the Local Plan Policies.

However the Duty to Cooperate is not a duty to agree!

The Inspector has indicated that CPBC have failed to fulfil the expected working practises.

The Duty to Cooperate was created in the Localism Act 2011.

During September 2014 a senior Planning Inspector held a “Secret” training session with CPBC senior officers and councillors.

Following a briefing I learnt that the Inspector, Mr K.Holland, made very clear that CPBC were expected to;

“Objectively assess its Housing Needs, Plan to meet those Needs, and very importantly undertake the Strategic Planning using the Duty to Cooperate that used to be done at Regional level.”

He pointed out that the Government is “completely uncompromising about these points”!

This, I was told, was the very first point that he stressed to the councillors and officers.

However the meeting was arranged as councillors were seeking to protect Castle Point Green Belt and wished to hear what options were available to them.

It is likely that councillors may have missed the Inspector’s opening warning regarding the Duty to Cooperate, however it would Not Have By-Passed the Officers!

Having found that CPBC could not meet its Housing Needs, and settled for 50% as a target, the Local Plan2016 then further sought a reduced target of 25% of Housing Need.

This would clearly indicate that much work and involvement with neighbouring Boroughs, to examine whether agreements could be reached over sharing Housing Delivery, would be a fundamental requirement.

Instead the Local Plan 2016 was submitted for Examination, knowingly failing the Duty to Cooperate, and supported by the 2013 Green Belt Boundaries review written in support of the rejected draft 2014 local Plan.

In other words the local Plan2016 was submitted knowingly doomed to failure!

 The local government Assoc. Consider “Holders of public office are accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this.”

Given the time and expense, reaching many, many hundred of thousand of Pounds to Castle Point residents, it is surprising that the belatedly undertaking of steps to fulfil the Duty to Cooperate, and the likely emergence of Local Plan Mk IV, has commenced without any apportionment of blame on the local authority, nor apology issued  to Castle Point residents, nor explanation of the reason behind the decision to submit a local Plan that would fail at the first requirement! 

View the Echo comment and Green Belt part of the allegedly leaked cpbc video HERE

Echo ‘Why press freedom is vital in our democracy,’ except where Castle Point Council is Concerned?

Are Castle Point Council preparing the first steps to demolish the Paddocks?

Could it also be that Canvey Island residents are being Censored by the Echo Newspaper on Behalf of Castle Point council?

stock-vector-censored-stamp-208931752

Following the exhaustive Leveson judicial public inquiry into the culture, practices and ethics of the British press,  the Echo Under a banner Headline proclaimed; 

‘Why press freedom is vital in our democracy’

“Imagine a world where newspapers were unable to challenge hospitals over care and councils over spiralling costs.”

“Imagine a world where newspapers were fearful of taking their MPs to task over government policies.”

We must wholeheartedly support their dedication to democracy on this issue, especially on many occasions the Echo’s investigative journalism has in the past exposed many important issues.

However it has been brought to our attention that perhaps all may not be quite so transparent!

A Canvey resident has informed us of a letter he sent to the Echo regarding his concerns over Castle Point council’s approach towards certain issues.

The Resident apparently persisted with enquiries as to why the letter had not been published, and only following contact from the Echo to verify his credentials, did the letter eventually appear in the Letters column!

Why would the Echo delay in publishing a Canvey resident’s letter on a Castle Point matter, rather than reproducing at the time the information was topical?

This is not the first occasion, as at least one of the Canvey Green Belt Campaign group’s letters was also only printed following re-submission.

Now we learn of  yet another Letter from a different Canvey resident that has also been delayed from publication.

This time querying Castle Point council’s intentions for the Paddocks!

The Canvey Resident’s letter explained fears that, despite the reassurances of cllr Smith, concern remained for the continued existence of the Paddocks Hall, the number of Car Parking spaces already shared with the Health Centre and the possibility of the partial release of the site for more Town Centre Flats!

Once again this resident has not had his letter published, and has needed to write again, And then a third time, to ask the Echo staff to explain, WHY NOT?

We appreciate that what the Echo publish, or chose to omit, is entirely their perogative, but surely the Echo do not have to run a letter’s content past the powers that be at Castle Point council!

We note there is never a glut of Letters from Canvey residents printed in the Echo columns, whilst there are certain contributors that appear to find it easy to have their letters approved on a regular, often too regular, basis, despite many topics verging on being considered banal, or even more suited to a National Publication!

Maybe there is even a “Sensitive” Warning Alarm Bell that rings on the Echo Letters Desk when a Letter is received from a Canvey Island address?

The Echo asked us to “Imagine a world where newspapers were unable to challenge …councils.”

Is there a Transparency issue regarding Echo Editorial content and Castle Point Council?

We sincerely trust not!

If certain contributions from Canvey residents are becoming too sensitive for the Echo editor or Castle Point council for immediate publication, then there needs to be a closer inspection of what is considered “challenging” and yet fit for publication in Print, weighed against what appears on the Echo website!

The Echo allows, and fails to remove spurious, damaging and possibly libellous accusations of the receipt of “Brown Envelopes” and Back-handers, aimed at our Castle Point councillors, published under pseudonyms, to remain visible on the newspaper’s website!

And yet Canvey residents have difficulty in legitimately calling into question Castle Point council cabinet decisions, through the Echo Letters column!

Image credit: Shutterstock

 

Thorney Question of Over-developing a Small Island in Castle Point!

Given that there is a possibility Canvey Island may suffer another Tidal Flood, given that we may again suffer from Surface Water Flooding as in 2013 and 2014, given that there may be another leak of LPG from Calor Gas, given that OIKOS have been granted permission by CPBC to increase activities in the importation, storage and blending of butane, and however small the risks, should not the Distribution of Housing Growth as imposed by Castle Point Borough Council (cpbc) be called into serious Question? *

Already there are over 38,500 residents on Canvey Island. If there were to be a major incident from just one of these four sources, an Evacuation of the Island, given the population level, the lack of access / egress routes and there being No Means of Warning, would be an impossibility. Is it time to cap the population level? We believe it is!

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Rather than accepting these “dangers” the powers that be at cpbc, appear to have their eyes and ears covered to blot out the concerns of the population on Canvey Island exposed to possible incidents in the desire to offset Housing and Business development away from the controlling mainland part of the Borough. Little wonder there is an active group hoping to convince the Boundary Commission to leave the Borough’s borders alone!

The denial of Climate Change, the absolute faith in our sea defence, the faith in the “hard work” undertaken to “maintain” the Island’s drainage system and the assurances from the two Top Tier COMAH sites, amount to little more than roll off the tongue Platitudes!

We stand accused of scare-mongering, then so be it!

We call it living in the Real World and “facing” realities. Fore-warned is Fore-armed.

Canvey’s highway infrastructure is restrictive, all routes converging at Waterside Roundabout, meaning evacuation is impossible and our limited Fire and Rescue cover means response times for assistance are likely to be prolonged.*

Green Belt is protected in planning terms by the Very Special Circumstances needed before the consideration of any development proposal.

Consider that, against a development proposal within a Flood Risk Zone and within the Consultation Distance of a Major Hazard site!

This is what requires not only for planning considerations, but also leading council members and officers to consider their consciences, with the proposal to develop 113 dwellings at Thorney Bay, Canvey Island.

This is only the first phase of a major development consisting of “approximately 600 dwellings” plus “Park Homes.”

The cpbc planning portal indicates that the developer may have overcome, to cpbc’s satisfaction, the requirements of the HSE, the Environment Agency and Essex County Council, the surface water drainage experts.

However these agencies lifting of Objections should not be seen as them giving their Approval!

In fact their concerns indicate that they Do Not Rule Out the Possibility of one or other Incidents occurring in the Future!

Within their comments they give very distinct warnings and concerns and indicate quite clearly the final decision and the Responsibility is Castle Point council’s ALONE!

Below are a few of the consultee agencies points of concern over the Thorney Bay proposal and further below are links to some previous incidents etc of some interest.

The Environment Agency state;

Our role is to provide you with our assessment of the risk for matters within our remit so that you can make an informed decision

“The FRA (flood risk assessment) proposes no detriment in off-site flood hazard for the design and extreme floods and manages this via a proposed embankment, subject to condition.”  Approval of the design of the proposed embankment is therefore necessary as a pre commencement condition, as the embankment is essential to safeguard against the offsite impacts. Without the construction of the embankment off site impacts would be seen

Provided you consider the development meets the requirements set out in the NPPF, including that it is safe for its lifetime and does not increase the risk of flood risk off site, we request that the following conditions are appended to any permission granted. Without these conditions our objection will be maintained.

Flood Risk Responsibilities for your Council    

We have not considered the following issues as part of this planning application as they are not within our direct remit; nevertheless these are all very important considerations for managing flood risk for this development, and determining the safety and acceptability of the proposal. Prior to deciding this application you should give due consideration to the issues below. It may be that you need to consult relevant experts outside your planning team.     

Safety of the building 

 Safety of People (including the provision and adequacy of an emergency plan, temporary refuge and  rescue or evacuation arrangements) 

Flood recovery measures (including flood proofing and other building level resistance and resilience measures) 

Whether insurance can be gained or not

Sustainability of the development – we advise you consider the sustainability of the development over its lifetime.

Your attention is brought to the proposed Roscommon Way Extension that is likely to pass immediately to the south of this proposed development site. Consideration is required of residual tidal flood risk at a master planning level to evaluate if further proposed phases of the Thorney Bay caravan park development could become less deliverable, unless suitable mitigation measures are identified and designed, with regards to breach characteristics – mainly depth, time to inundation and hazard ratings. Future proposed Flood Risk Vulnerability Classification will need to be considered alongside the residual tidal flood risks to ensure a sequential approach to future site layout is maintained.

 

ECC Lead Local Flood Authority position;

Having reviewed the Flood Risk Assessment and the associated documents which accompanied the planning application, do not object to the granting of planning permission.

Condition 1

 No works shall take place until a detailed surface water drainage scheme for the site, based on sustainable drainage principles and an assessment of the hydrological and hydro geological context of the development, has been submitted to and approved in writing by the local planning authority. The scheme should include but not be limited to:

  • Final modelling and calculations for all areas of the drainage system.
  • A final drainage plan which details exceedance and conveyance routes, FFL and ground levels, and location and sizing of any drainage features.

Reason:

  • To prevent flooding by ensuring the satisfactory storage of/disposal of surface water from the site.
  • To ensure the effective operation of SuDS features over the lifetime of the development.                 
  • To provide mitigation of any environmental harm which may be caused to the local water environment                                                                                                                                                            
  • Failure to provide the above required information before commencement of works may result in a system being installed that is not sufficient to deal with surface water occurring during rainfall events and may lead to increased flood risk and pollution hazard from the site.

Condition 2

 No works shall take place until a scheme to minimise the risk of offsite flooding caused by surface water run-off and groundwater during construction works and prevent pollution has been submitted to, and approved in writing by, the local planning authority.

Reason

 The National Planning Policy Framework paragraph 103 and paragraph 109 state that local planning authorities should ensure development does not increase flood risk elsewhere and does not contribute to water pollution.

 Construction may lead to excess water being discharged from the site. If dewatering takes place to allow for construction to take place below groundwater level, this will cause additional water to be discharged. Furthermore the removal of topsoils during construction may limit the ability of the site to intercept rainfall and may lead to increased runoff rates

Health and Safety Executive state;

More than 10%of the housing development lies within the middle zone, – through the HSE Planning Advice Web App advised Against the granting of Planning Permission.

However, having given more detailed consideration, HSE has concluded that it is appropriate for HSE to provide case-specific advice on this proposal outside of the codified planning methodology provided.

The layout indicates that a total of 30 dwellings at a housing density of 38 dwellings per hectare within the middle zone.

HSE’s advice is that significant housing should be prevented from being built in the inner zone and only a limited number of houses at a low density.

The overall objective is to maintain the separation of incompatible development from the Major Hazard.

HSE would advise Against any planning application which seeks to locate any additional dwellings within the middle zone of Calor Gas Ltd.

Instead of using the HSE Planning Advice Web App, Castle Point Borough Council should therefore consult HSE directly for advice on any future planning applications which propose further residential development at Thorney Bay Park within the middle zone of Calor Gas Ltd.

*Below are links to;

*Reduction in Essex Fire and Rescue Service cover view HERE

*Calor Gas Leak court decision view HERE

*OIKOS permission granted view HERE

Editor. It should be pointed out that any emphasis included in the text is the author’s.

 

Local Plan, Neighbourhood Plan, No Plan, Leaves all of Castle Point at Risk?

It is common knowledge that Canvey Island town council (citc) was requested by the Canvey Green Belt Campaign group to undertake a Neighbourhood Plan for the Island.

Following some investigative work by the Town Clerk the initiative was democratically rejected by the full council.

train crash

We remain convinced that a Neighbourhood Plan would, in the distinct possibility that the Borough’s Local Plan2016 were to hit the barriers, act as a valuable document indicating the areas and buildings worthy of protection, indicating clearly the Constraining factors limiting further development and creating a safer community, for the Planning Inspector to use as a positive democratic indicator of Canvey Island residents vision for our Island.

The Government website states

“Neighbourhood planning enables communities to play a much stronger role in shaping the areas in which they live and work and in supporting new development proposals. This is because unlike the parish, village or town plans that communities may have prepared, a neighbourhood plan forms part of the development plan and sits alongside the Local Plan prepared by the local planning authority. Decisions on planning applications will be made using both the Local Plan and the neighbourhood plan, and any other material considerations.”

“Neighbourhood planning can inspire local people and businesses to consider other ways to improve their neighbourhood than through the development and use of land. They may identify specific action or policies to deliver these improvements. Wider community aspirations than those relating to development and use of land can be included in a neighbourhood plan” 

The “other material considerations” are crucial to our area!

They are not best supported through any Local Plan alone!

With this in mind and given the criticism from mainland sources, towards citc for not progressing with a Neighbourhood Plan, we must wonder why no mention nor proposal for a Neighbourhood Plan has emerged in any single area of the Castle Point mainland!

Given that mainland areas have been most vociferous in their objections to proposals for development and given the supposedly undemocratic (allegedly officer led) development of a Local Plan from the Core Strategy days, it is a wonder that one or another group has not been formed to process a mainland Neighbourhood Plan.

This may be the result of One version of the Local Plan indicating one area of mainland Green Belt being suitable for Housing Development, whilst an emerging Plan indicating otherwise.

One can only assume that mainland residents are either content with the current Local Plan2016 having faith in their councillors, or believe the LP2016 will fail meaning it possible, or likely, that the previous draft Local Plan (2014 version?) will prevail.

This may indicate residents total faith in their councillors or may raise the question of what the value is in Localism and the Neighbourhood Plan process, if any at all!

What Canvey Islanders can be sure of is the need to defend Canvey against unreasonable development, because at the moment both Housing and Business Development is being approved, regardless of Constraints. We believe a Neighbourhood Plan, whether in agreement or conflict of the Local Plan2016, and at whatever stage of production, is a means of documenting Canvey’s issues.

To have a document in the form of an emerging Neighbourhood Plan would be invaluable to an Inspector to consider against a possibly UnSound Local Plan!

To rely on verbal evidence during Examination is a Risk. Indeed an Inspector may limit participation in the Examination in Public only to residents and groups who have previously submitted written evidence through the consultation process.

Looking at the lack of submissions on behalf of Canvey Island this could be a problem.

As indeed it could be for all of Castle Point as the Local Plan, whichever version is Examined, will be Supported by the Evidence of CPBC Officers, and in many areas this may be unforthcoming!

The extent of the considerations of Canvey Island town council into the undertaking of a Neighbourhood plan are recorded in the citc minutes for 15th August 2016;

CO/065/16 – TO CONSIDER AND AGREE PREPARING A NEIGHBOURHOOD PLAN OR NEIGHBOURHOOD DEVELOPMENT ORDER Cllr M. Tucker advised members that he would read through the report, inviting members to ask questions at each stage.

Cllr T. Belford enquired whether any members of the Neighbourhood Plan Working Group set up to investigate the merits of having a plan were present to give a report of their findings.

Cllr M. Tucker advised that the findings were detailed in the report provided.  Cllr M Tucker proceeded to read the report to members.

Cllr M. Tucker asked the Town Clerk to provide information on the investigations carried out on the appointment of Neighbourhood Plan Co-ordinators.  The Town Clerk advised members that she had carried out investigations into other Parish and Town Council’s who had resolved to progress a Neighbourhood Plan and found that many had appointed Planning Co-ordinators to write the policies.  She explained that an average hourly rate of £12.00 per hour was advertised for appointments and that she had been advised by one Parish Council that during the busier periods of policy writing, the appointment had been on a full time basis.

Cllr M Tucker proceeded to continue to read the report to members.

Cllr M. Tucker invited questions.

Cllr T Belford commented that he had failed to understand that anything that was detailed in the existing Local Plan or proposed Plan must remain and cannot be conflicted.  Cllr T Belford added that he had thought that by completing a Neighbourhood Plan it would enable the Town Council to make representation to the Borough Council to say that it thought that it had not designated development properly and could suggest where development should be.  He added that having reviewed the paperwork he did not believe that completing a Neighbourhood Plan would achieve what he thought it could have.  Cllr T. Belford apologised to Mr Bracci as he had bought it to the Council to consider, explaining that he had misunderstood what a Neighbourhood Plan could achieve.

Cllr D Blackwell commented that everyone he had spoken with believed that by progressing a Neighbourhood Plan it would stop development.  He explained that Government statistics show that Parish and Town Councils that have progressed Neighbourhood Plans have, on average, increased development by 10% in their area which is not what the residents of Canvey Island want.  Cllr Blackwell commented that he had spoken with Steve Rogers the Head of Regeneration and Neighbourhoods at Castle Point Borough Council and he had said that all development sites already in the Draft 2016 Local Plan for Canvey Island would have to be carried forward into the Neighbourhood Plan.

Cllr D. Blackwell commented that in his opinion the Government inspector will review the Draft 2016 Local Plan and it will be rejected.  He explained that they will then give the Borough Council six months to submit a new Plan.  He commented that in his opinion, there will be a public enquiry and when the Inspector launches this it will be a great opportunity for the residents of Canvey Island to give evidence of the constraints faced on Canvey Island including COMAH sites, flooding and the fact that it has traffic problems.  He added that he thinks there is a very strong case to challenge the delivery of development on Canvey Island even though it has been designated in the Draft 2016 Local Plan.

Cllr D. Blackwell advised that he had looked at Government Guidelines which state that you should not build on flood risk 3 areas until all other options had been exhausted.

Cllr D. Blackwell added that most other Parish Councils that have introduced Neighbourhood Plans are rural and have plenty of land surrounding them where they can take more housing, however, Canvey Island is an urban council with lots of constraints.  Cllr D Blackwell commented that he agreed with Cllr T. Belford recommended that the Town Council should not proceed to progress a Neighbourhood Plan.

Cllr M. Tucker commented that he understood the concerns regarding the Dutch Village site, however, advised that new planning laws state that any development proposed to be built on a flood plain would be sent Government Ministers for consideration and also stated that any development already designated in the Local Plan must be considered as having outline planning permission.

Cllr J Blissett commented that she understood that the Dutch Village site had been removed from the Draft 2016 Local Plan.  Cllr M. Tucker commented that the site had been taken out to balance development across the Borough.

Cllr D. Blackwell commented that when the Draft 2016 Local Plan is rejected and unless the Borough Council can come up with a feasible plan, the Government will step in and deliver a Plan and there will be no control over the designation.

Cllr J. Blissett enquired about whether development on a flood plain is preferred over development on greenbelt sites in Benfleet.

Cllr D. Blackwell advised that all government guidance says that building on a flood risk areas should be the last possible option.

Cllr B. Campagna recommended that the Town Council should formulate a representation to present to the Inspector at the time of the public enquiry.

Cllr D. Blackwell explained that the Government Inspector will work with officers initially to discuss the Local Plan and will then look at all the evidence of the constraints that are in place on Canvey Island.

Cllr D. Blackwell advised that any person that wishes to have a say at the public enquiry must lodge their objection to that Draft 2016 Local Plan to enable them to speak at that enquiry.

Cllr M. Tucker advised members of the Clerks RECOMMENDATION.

Cllr T. Belford commented that this recommendation should only be considered if the Council agree to take this forward.

Cllr J. Anderson commented that the information detailed in the report provided is sufficient to make an informed decision and that there should be no need for further investigation in this matter with the RCCE and DCLG.

Cllr M. Tucker asked members for their RECOMMENDATION.

Cllr D Blackwell RECOMMENDED that following investigation into the merits of progressing Neighbourhood Plan that the Town Council go no further with the Neighbourhood Plan.

Cllr B Campagna seconded this RECOMMENDATION.  Cllr M. Tucker asked members to vote on this RECOMMENDATION with a show of hands.

Members voted and unanimously RESOLVED not to proceed to progress with a Neighbourhood Plan.

This month’s Castle Point Council meeting, on the 29th March, is expected to give consideration of a suitable response to the Planning Inspector’s criticisms of the Local Plan2016 and the failure of cpbc in its Duty to Cooperate.